Brian Beals, LLC

Section 504 for Healthcare

The HHS final rule at 45 CFR Part 84 sets WCAG 2.1 Level AA as the standard for web content, mobile apps, and electronic documents. If you take Medicare or Medicaid, it reaches you.

The rule took effect July 8, 2024. On May 7, 2026, the HHS Office for Civil Rights issued an interim final rule moving both compliance dates out by one year, so a date you wrote down before that has changed.

Who counts as a recipient

Any recipient of HHS federal financial assistance. Hospitals and health systems, federally qualified health centers and community health centers, physician and dental practices, behavioral health, dialysis, long-term care, home health, health plans, research institutions, medical schools, and human services programs.

Medicare and Medicaid participation is federal financial assistance for this purpose, which is what pulls in nearly every provider in the country. Federal procurement contracts and contracts of insurance or guaranty are not. This is the point most organizations get wrong, usually by assuming that not holding a grant means not being a recipient.

Enforcement runs through HHS OCR investigations and compliance reviews, with loss of federal funding at the far end. Section 504 also carries a private right of action, so a complaint does not have to start with the agency.

The part about your documents

The rule exempts electronic documents that existed before your compliance date. Read the next clause carefully, because it is where the exemption stops:

The exception does not apply where such documents are being utilized by individuals to apply for, access, or take part in a recipient's program or activity.

That sentence puts every patient-facing document back in scope regardless of when it was published. Intake and registration forms. Consent forms. Financial assistance and charity care applications. Notices of privacy practices. Patient education material. Anything hanging off the portal. The date it went up does not matter if a patient uses it to get care.

A mid-size health system has thousands of these across departments, service lines, and clinic microsites, accumulated over a decade by people who have since left. Ask a compliance officer how many patient-facing PDFs are on their web properties and the honest answer is that nobody knows. That unknown denominator is the actual problem. You cannot plan remediation, budget it, or tell OCR what you were doing about it without a number.

Start with the count, not the repair

The first engagement is a baseline inventory: every patient-facing document discovered across your web properties, each one tested for tag structure, reading order, language, headings, table headers, and alternative text, sorted by whether a patient uses it to apply for or access a program. You end with a count, a prioritized list, and a defensible record of the date you established both.

The website evaluation runs alongside it and produces an Accessibility Conformance Report in VPAT 2.5 format against all 50 Level A and AA success criteria of WCAG 2.1, each one marked and evidenced, dated and signed. Periodic re-testing after that, because a document library drifts: every new form uploaded without tags moves you backward, and a count taken once is a count that was true once.

Why I do not remediate

A conformance claim written by whoever repaired the documents is a self-assessment. The evaluation has to come from outside the repair work or it is the vendor grading their own homework, and your counsel will say so.

Staying out of the repair also gives you a specification your remediation vendor bids against, instead of a per-document quote you have no way to check. I am happy to refer a partner for the repair. I will not hold both ends.

An overlapping obligation worth knowing

Public hospital districts and other government-operated providers are covered by ADA Title II as well, at 28 CFR 35.200, with its own dates of April 26, 2027 and April 26, 2028. The two obligations are independent and both apply. The one that binds is whichever arrives first, which for most districts is the Section 504 date.

This matters in one direction people miss. Section 504 follows the federal funding rather than the corporate form, so a district that converts to a private nonprofit leaves Title II and stays a 504 recipient. See the Title II and Section 508 practice if that is the side you are on.

The proof

This site carries its own Accessibility Conformance Report. Fifteen pages and all four published documents evaluated against all 50 Level A and AA criteria on August 14, 2026: 36 Supports and 14 Not Applicable, with zero criteria failing. The document layer passed too, every PDF tagged with structure, language, and headings verified. Read the full conformance report. It is the same document a client receives, produced by the same process. The fastest way to judge whether the work is any good is to read one.

The firm

Brian Beals, LLC. Service-disabled veteran-owned small business, based in Punta Gorda, Florida.

SDVOSB / VOSB

SBA-certified, certified August 6, 2026

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Getting started

Twenty minutes is usually enough to tell whether this is worth your time. I will walk you through what the rule reaches at an organization your size and what a baseline inventory would cover. If the timing is wrong, say so and I will leave it alone.

Get in touch, write to brian@brianbeals.com, or call 941-979-6282.